National Women's Council of Ireland Pre-Budget Submission 2020 Department of Employment Affairs & Social Protection

National Women's Council of Ireland Pre-Budget Submission 2020 Department of Employment Affairs & Social Protection
National Women’s Council of Ireland
   Pre-Budget Submission 2020

  Department of Employment Affairs
          Social Protection
National Women's Council of Ireland Pre-Budget Submission 2020 Department of Employment Affairs & Social Protection
Established in 1973, the National Women’s Council of Ireland (NWCI) is the leading national
women’s membership organisation in Ireland. NWCI seeks full equality between men and women
and we draw our mandate from a membership of over 180 groups and organisations across a
diversity of backgrounds, sectors and locations. We also have a growing, committed individual
We actively support and work with government to implement the National Strategy for Women and
Girls (NSWG) to secure full participation in education, employment and public life at all levels, and to
improve services for women and girls. NWCI actively works to prioritise the needs of those
experiencing, or at risk of experiencing, the poorest social and economic outcomes.

Our submission to the Dept. of Finance and Public Expenditure & Reform outlines the broader
macroeconomic framework that this submission takes as its context and will therefore only highlight
key points relative to this department’s responsibilities.

We welcomed the 2019 Budget focus on child poverty from the Department of Employment Affairs
and Social Protection (DEASP) and the restoration of some income disregards for lone parents, the
modest increases in other carer, disability and benefit payments. The importance of adequate social
protection and social welfare for preventing deprivation and poverty continues to be highlighted by
the fact that without the social welfare system 43.8% of the Irish population would have been living
in poverty in 2017. Persistent poverty, including that of children, is heavily concentrated in lone
parents, the vast majority of whom are women. NWCI believes a concerted programme of gender
aware and gender proofed investment is needed to realise the current potential shift towards a
more equal economy and society, particularly for those women and families most at risk of poverty
and inequality.

Budget 2019 delivered welcome moderate increases to the minimum social welfare payment.
Further increases of social welfare payments should be benchmarked at a level which is adequate to
both lift people above the poverty line and provide them with a Minimum Essential Standard of

Although the official level of employment is close to its highest level ever, NWCI argues we are not
approaching what could be called ‘full employment’ as long as women’s participation rates remain
low and so many women are underemployed. The NESC report in 2018 on low work intensity
households2 estimates that 150,000 qualified adults are either unemployed or under employed and a
significant proportion of these are women. The graphic below shows the gap between those
officially unemployed and other groups that are not at work, and this also includes a significant
proportion of women.3

  NWCI welcomes the commitment to consultation on the benchmarking of social welfare payments The Social Welfare,
Pensions and Civil Registration Act 2018
  NESC Low Work Intensity Households 2018
  SJI Budget Choices 2020

National Women's Council of Ireland Pre-Budget Submission 2020 Department of Employment Affairs & Social Protection
(Non employment index +2.5% above unemployment rate in 20164

Ireland 2040 is biased towards infrastructural investment and Budget 2020 must focus on the
potential benefits of more immediate social investment especially for those without access to a
market income. This is particularly the case with investment in early childhood education and care
(ECEC), where there are well documented multipliers in relation to employment and local economic
development, which both EU and national evidence demonstrates provides a clear social gain on
such investment. NWCIs know the lack of investment will inevitably keep, or transfer back, personal,
health and community care needs to the unpaid, undervalued and often invisible labour of women.

Gender budgeting
NWCI works with the Dept. of Public Expenditure & Reform on the Equality Budgeting Expert
Advisory group to advance the integration of gender (and progressively other equality budgeting
processes) into the annual budget process and the delivery of public services. An Equality Impact
Statement published alongside Budget 2020 should be the next step in this process.

For DEASP the Equality Impact Statement should emphasise fiscal policies which include
            Full individualisation of the tax and welfare system
            Continued increases to social welfare payment levels-an additional €8 in Budget
            Progressive benchmarking of payments and stronger link to a Minimum Essential
               Standard of Living (MESL)
            Ensuring adequate investment for affordable quality childcare & secure work force
            Providing for increased parental leave
            Supporting a secure, flexible working environment
            Progression to standard rating of pension tax reliefs
    A non-employment index for Ireland Byrne, Conefrey 2017
    SVP Investing in A just Society 2019-Progress to a MESL rate

Social Protection
The submission will outline opportunities to enhance women’s economic independence through
labour market participation. We will equally emphasise and welcome the important role of the
social welfare income support system and its relative effectiveness at reducing market income
poverty and inequality. It is time to fully individualise the tax and welfare system and to more
systematically review current payment levels, and plan for increases to progressively benchmark
payments to a Minimum Essential Standard of Living (MESL).

Social insurance
We welcome the NESC working group on social insurance and believe that this has potential to
realise the objective of enhancing social insurance policy. We ask that this group has the resources
and skills to gender their analysis. It is clear that the Irish social Insurance model was built for a
different era on a largely male breadwinner understanding of both the labour market, social welfare
and taxation system. An enhanced social insurance system has some advantages from the
perspective of gender, opening up options for individualisation, pay related payments and high
levels of payment relative to minimum income payments. However, research also shows social
welfare systems based on rewarding economic participation do not always work for women. Further
pre and post crisis changes have increased social insurance eligibility and entitlement criteria and
reduced pro-rata payments for part time workers, mainly women. We welcome the extension of
social insurance to the self-employed, but we ask that the impact of this reform be monitored for its
gender impact. A gender sensitive reform of social insurance needs to factor the reality that women
have lower levels of economic participation and work more part-time hours.

Affordable Childcare
We recognise it is not the responsibility of DEASP, however affordable early childhood education and
care (ECEC) remains one of the most significant barriers to women’s equal participation in all aspects
of society, particularly employment, education and training. NWCI also highlights to DEASP how
inadequate investment in ECEC is creating a poorly paid, un-pensionable female dominated
workforce, many of whom are dependent on summer month social welfare supports and other
income supports.       We further highlight recent concerns of potential negative consequences of
inadequate funding for lone parents, moving from the Community Childcare Subvention Scheme to
the National Childcare Scheme.

We ask that the DEASP & Department of Children and Youth Affairs (DCYA) continue and broaden
how they work together to ensure that investment in this key social infrastructure meets the needs
of women and children, particularly those most at risk of poverty and exclusion.

Women, vulnerability and poverty

Specific social welfare issues for the most vulnerable women
Women who are Asylum seekers
   The value of the rate of €38.80 Direct Provision Allowance secured in Budget 2019 should
     not be eroded by ordinary costs of living increases
   Grant Child Benefit to all children irrespective of the status of the parents
   Extend Free Travel Scheme to people in the protection process

Young Women
    NWCI welcomes the YESS programme, however in light of the direct link between increased
       rates of poverty and homelessness, and the very high rate of severe deprivation amongst
       young people 18-24, the full rate Jobseekers Allowance must be restored as a matter of
Traveller women
    Develop a fully gender proofed national Traveller employment strategy as part of the
       National Action Plan for Jobs, and Pathways To Work (PTW) to take account of barriers to
       participation of Traveller women, such as access to culturally competent affordable
Women with a disability
    Deliver a cost of disability payment, minimum €20 per week6

Lone parents
Lone parents, 84% are women, in Ireland are almost 5 times more likely to experience in-work
poverty than other households with children. 84% of lone parents in Ireland were unable to meet
unexpected expenses and almost 60% of lone parents reported that they could not access childcare
services due to cost. In terms of purchasing power, lone parents in Ireland have the fourth lowest
household income among EU-15 countries. While the household income of the general population in
Ireland has recovered to pre-crisis levels, the income of one parent households was lower in 2017
than in 2007.7 8

The Indecon 20179 & ESRI 201810 reports confirmed that lone parents in work have been penalised
by changes to lone parent social welfare supports. We welcome the reversal of income disregards
and the child maintenance disregard for the Working Family Payment (WFP) is a particularly positive
step towards the recognition of child maintenance as a separate and independent income for
children. However, persistent reductions in the income disregard for lone parents receiving the One
Family Payment (OFP) have resulted proportionally significant losses each week. Gradual reductions
to the OFP age threshold have moved significant numbers of lone parents onto the replacement
unconditional Jobseekers Transition Payment (JST). Though lone parents in receipt of the JST are not
required to seek full-time work and more flexible part-time work patterns are accommodated, those
who do work are not entitled to the Working Family Payment. NWCI repeats its call for the net
exchequer savings of €45.08m from the OFP reforms identified in Indecon 2017, to be utilised in a
programme of supports for the 48% of lone parents who have not increased earnings since the

As recommended by the Joint Committee on Social Protection there is an urgent need to establish a
Statutory Maintenance Authority to reduce the burden on women to litigate for child maintenance
order; there is a significant rate of non-compliance with child maintenance orders, significant delays
in the courts system and a high cost involved in engaging a litigious route.

  NWCI welcomes DEASP commissioning research to establish real cost of disability & €20pw is an interim recommendation
  Society of St. Vincent de Paul ( 2019) Working Parenting and Struggling
  Research from Europe shows that this pattern is not unique to Ireland & and that increases in the labour market
attachment of lone parents does not necessarily reduce their poverty risk. (Jaehrling, K., Kalina, T. and Mesaros, L. (2015)
‘A paradox of activation strategies: Social Politics, Vol 22
  Independent Review of the Amendments to the One-parent Family Payment since January 2012
  ESRI Lone-parent incomes and work incentives

NWCI Recommends
Reinforce commitments to reducing deprivation and child poverty levels, particularly in
lone parent families as a priority in Budget 2020.
         -     Restore income disregards to all categories of lone parents on OFP and JST to €165pw
         -     Increase the income disregards for lone parents on OFP and JST to support take up of
               increased working hours
         -     Reduce the hours requirement for the Working Family Payment for lone parents to 15
               hours per week
         -     Allow lone parents to receive both the JST and WFP. Extend the cut off for the Jobseekers
               Transition Payment until their youngest child reaches the age of 18
         -     Ensure lone parents on JST have access to SUSI grants for part-time study
         -     Exclude the Working Family Payment from the income assessment for the Differential
               Rent Scheme across Local Authorities
         -     Introduce comprehensive financial support to cover the full costs of attending a training
               course, including childcare and transport
        Establish and resource a Statutory Maintenance Authority

Careful Activation - Low work intensity households
The number of people living in households with low work intensity remains one of the highest in the
EU, highlighting the need for more integrated and targeted activation strategies to support this
particular group.11 Moving from Welfare to Work (NESC 2018) highlights the importance of
household based strategies to address welfare to work barriers for low work intensity families who
face a disproportionately high risk of poverty and deprivation. Enabling women in these households
to access employment is vital to address high poverty associated with low work intensity.

Pathways to Work (PTW) is a male bread winner activation model which presently demands full-time
work availability and a strong emphasis on mandatory over voluntary activation, this impacts directly
on access to support and opportunity for many women. Qualified Adults, 90% of them are women,
often live in jobless households yet they cannot access training of supports without committing to
full time availability. The new iteration of PTW due in 2020 must assess the gender impact of all
proposed changes.

We believe that with unemployment low and the number of qualified adults in job seeker
households declining, that there is an historic and affordable opportunity to abolish the limitation
rule and open up the prospect of individualised rights to social security and labour market supports
for women.

NWCI Recommends
            End the limitation rule and promote administrative Individualisation at first point of

     2019 European Semester: Country Report - Ireland

   Widen access to the Job Seekers Transitional Payment for qualified adults to enable
         access to quality part time education, training and employment opportunities as well
         as childcare supports
        Change eligibility rules to enable qualified adults access a range of active labour
         market policies (ALMPs), without such access there will be little incentive for them to
         participate in pilots
        Resource a national survey to ascertain skills education, health, care and
         employment experience of qualified adults
        Resource community based organisations to work with the economically & socially

Labour Market: The Gender Dimension

A gender aware understanding of full employment will draw attention to the reality of the gap
between male and female labour market participation. Irish female labour force participation rates
are lower than average European rates with a rate of 56.1 % Q1 1912 that maintains greater
differences between male and female participation rates in Ireland compared to the EU. The
employment rate for Irish females with children is below the EU-15 average and the gap to the EU-
15 average widens with the movement from 1 to 2 children.13

Table 1

     Social Impact Assessment, Female Labour Force Participation(2018) Department of Public Expenditure and Reform

Chart 1: Gender divides in labour force participation, Ireland 1998-2017

Females accounted for 70% of PT workers in Q4 2017 (321,600 workers), 69,000 of these female
workers classified themselves as involuntary part time or underemployed (three-in-five or 60% of all
underemployed PT workers). Women who are presently unattached or marginally attached to the
labour market including those voluntary or involuntary underemployment need to be a specific
target of any national productivity strategy. The insufficient provision of childcare is a central cause
of high female inactivity but so too is the cultural gap between male and female participation in
household work, elder care and emotional labour. In 2017, 54.2% of inactive Irish females
reported caring responsibilities as the main reason for inactivity, against an EU average of
Table 2: Employment by gender, full time and part time

     2019 European Semester Ireland Country Specific Report

Chart 2: Reasons for women working part time

NWCI welcome the increased investment in apprenticeship schemes15 however analysis indicates
that in 2018, Irish apprentices are almost exclusively (85%) young men under 25 years of age. Of
14,953 apprentices completing training in October 2018, just 332 or 2% were women.16

A gender analysis of Budget 2019 investment in AMLP shows clear gender bias in end-recipients of
ALMP investment including the high profile apprenticeship programme.17

Table 3: Gender analysis of women’s access to budget 2018 ALMPs

   Solas-Pathways Apprenticeship Review Nov 2018
   NWCI-No Feminist Budget, Dr. M. Murphy

Gender pay gap and low pay
The economic cost of being a woman, the gender pay gap, (GPG) stands at 14%.18 This reality has
serious implications for a woman’s lifetime earnings, her career decisions and her ability to live in
older years with a decent income. We know the GPG almost trebles between 30’s and 40’s, when
women are stepping away from the workforce for caring responsibilities (children or broader
The ‘unexplained’ part of the gender pay gap, actual pay discrimination will be significantly
challenged by the new Gender Pay Gap legislation and we welcome its introduction. However, this
must be matched by well-resourced monitoring and reporting structures.

Women make up a higher percentage of the low paid in Ireland. The LPC 2016 found 60% of
minimum wage workers were female while the NERI (2015) report “A Profile of Those on The
Minimum Wage”, found that 64.7% of minimum wage workers were women, while in 2014 50% of
women workers earned less than 20,000 pa19. Part-time workers account for over 50% percent of all
National Minimum Wage employees and approximately 80% of these are female. Women
dominated employment sectors have been subject to aggressive casualisation and the erosion of pay
and security. Research from the US and across the EU shows that collective bargaining mechanisms
are critical to closing the gender pay gap20 and DEASP should publicly support the development of
these instruments in these female dominated sectors.

Chart 2: Low pay by gender in Ireland 2012-2015

Workers represent 14.3% of all those in poverty.21 Without social transfers and in-work payments
such as WFP many households would not be able to survive. The cost to DEASP of these in-work
supports is up to €2b, essentially a subsidy for poor quality employment. These workers face

   The GPG widened from 12.6% in 2006 to 14.4% in 2012. The decrease to 13.9% is welcome but hardly substantial
   LPC (2016) The preponderance of women on the national minimum wage
   The Gender Wage Gap:Blau Kahn (2016) IZA
   SJI Poverty in Focus 2019

unpredictable schedules and can find themselves penalised by payment structures and rules based
on daily work patterns that are outside their control.

Despite the existence of protective laws, the ESRI study Pregnancy At Work: A National Survey found
that 30% of those who worked while pregnant experienced discrimination. A similar figure reported
problems relating to maternity leave.22

NWCI recommends
            Gender-proof new labour activation initiatives and review their gender impact
             before scaling up
         -     Ensure a gender sensitive monitoring of the activation initiatives and ensure workers are not
               pressured to increase hours while maintaining care obligations
         -     Ensure no-one required to accept insecure, non-fixed hour jobs as ‘reasonable offer of work’
         -     Recognise atypical work patterns by calculating unemployment on hours rather than days
               per week
            Champion Quality, Decent work
         -     DEASP publicly support collective bargaining instruments
         -     Improve take home incomes at source by supporting raising wages and taking action against
               precarious, low paid work
         -     Support additional legislation and regulation to tackle if and when contracts, bogus self-
               employment contracts and support banded hour contracts
         -     Attach social criteria, clauses and conditionality to Employer incentive schemes
         -     Advocate for adequate resourcing of government procurement processes to proactively
               ensure living wage social clauses in key sectoral procurement processes in female dominated
            Actively champion an increase in Minimum Wage and an LPC focus on In-Work
         -     Drive Cross-Departmental cooperation to promote ‘Living Wage’ through policy and
            Make NWCI a full member of the Low Pay Commission
            DEASP & DCYA work together to ensure the National Childcare Scheme supports
             women to return to learning, training and work
            Resource the commissioning of an independent nationwide study on the prevalence
             and nature of pregnancy discrimination and disadvantage in the workplace.

Gender sensitive pension reform

Ireland’s gender pension gap stands at 26% and gender-sensitive pension reform is a priority
for NWCI and our members. We welcome the government’s response to gender-based inequalities
and anomalies in the state pension system through the introduction of a Home Caring Period in

     Pregnancy At Work: A National Survey, which was undertaken by the Economic and Social Research Institute (ESRI 2011)

combination with a Total Contributions Approach (TCA) 23. However, the approach remains
piecemeal, with government tinkering on the edges of the system rather than making transformative
changes to achieve greater coverage and greater equality.

All women must have direct individual access to the state pension which takes into account the
important role women play in providing unpaid care24. Budget 2020 should deliver a full home caring
credit with retrospective application. This practical recognition of the social and economic
contributions of care should also serve as a re-entry credit. Longer periods of caring than currently
envisaged, must be recognised in the final design of the TCA to recognise carers of adults and
children with disabilities who may require a lifetime of care. It is critical that the contribution
requirement is not extended to 40 years, which would have significant detrimental impacts on
women in retirement, in particular migrant women and women with disabilities.

NWCI is increasingly concerned about the emphasis on increasing occupational, second tier pensions
through the development of the auto-enrolment scheme. Resources devoted to the development of
this will be diverted from first tier pensions without a clear analysis of how this will impact women
and workers in low-paid, part-time and precarious employment, predominantly also women25.
Women are less likely to benefit from occupational26 or private27 pensions in old age. National
pension policy must explicitly recognise and address this without disregard for the fundamental
importance of the first pillar.

Universal State Pension
NWCI concurs with Social Justice Ireland (SJI)28, Age Action Ireland (AAI), and the Pension Policy
Research Group (PPRG) that a universal pension system which gives women equal access to a
comprehensive pension guarantee is that the best way to support equality in older age. NWCI
continues to call for the introduction of a universal pension based on residency, which would
guarantee equal access to a comprehensive pension for all. NWCI rejects the idea of substantial cuts
on the rate of payment to fund a universal pension. A significant proportion of the €2.39 billion29
currently spent on private tax relief, 70% of which goes men as the highest earners, should be
reinvested in first tier state pension. We note that this funding option is not considered to fund a
universal pension in the DEASP 2018 Total Contributions Approach (TCA) consultation document.

NWCI Recommends

         Initiate the introduction of a universal state pension
         End Tax reliefs on private pensions
     -   Begin by removing marginal rate tax reliefs

   We are concerned by recent data from the DEASP that indicates that of the 58,979 review decisions flowing from these
changes that have been made, 33,738 have received no increases, a rate of just over 57pc
   The State will continue to depends on Non-Contributory Pensions which requires women to undergo a means test, and
the Widows Pension, which does not provide for women in their own right, but rather due to their status as a wife or civil
   Insecure & Uncertain’; Precarious Work in the Republic of Ireland and Northern Ireland, ICTU 2017
   The gender gap in occupational pensions is at 13.1%, which is relatively high by EU levels
   ESRI figures show private pension coverage at 94% in the highest income decile and as low as 18% in the lowest deciles
   A Universal State Social Welfare Pension: Recognising the Contribution of all our Senior Citizens SJI 2018
   Collins, Supporting Pension Contributions Through the Tax, System Outcomes, Costs and Examining Reform

    Resource & publish a gender impact assessment (GIA) of the TCA & Auto-
     -     Resource a GIA on projected increases in state pension age & subsequent pension reforms
          Deliver a full Homecarers credit that actively recognises the contribution of care
           and also serves as a re-entry credit
     -     Apply to women born before 1946
          Ensure the TCA is limited to 30 years for the maximum pension

Value care work and Support women’s economic independence

NWCI welcomes the Council of the EU majority adoption of a Directive on work-life balance for
parents and carers. Care work is essential to the common good and performs vital social and
economic functions, but it is neither prioritised nor sufficiently supported. Ireland’s care policies and
services for children, dependents, and older people, and statutory supports including maternity,
paternity and parental leave provisions, lags behind many of our EU partners. Women continue to
provide the majority of unpaid care hours, 98% of those looking after the home/family were women
in 2016.31 32 13.1% of those classified on home duties are poor and this group is disproportionately

Family Care Provision
We welcome recent additional support in training, support and grants from DEASP. Family carers,
predominantly women should have certainty that basic supports will be in place to maintain their
own health, to obtain respite support and to have access to financial support while they undertake

Homecare has been progressively privatised in Ireland to a largely unregulated home care industry,
with high fees, varied quality and standards of homecare provision, and poor terms and conditions
for workers. Domestic and personal care workers are often migrant women workers, and women of
colour, subject to the most extreme instances of precarious work and exploitation. NWCI is
particularly concerned that we must not become dependent on the exploitation of some of the most
vulnerable women workers to meet our personal, familial and community care needs.

The Department of Health’s plan to establish a statutory homecare scheme by 2021 is welcome, but
interim measures are required.

NWCI Recommends (DEASP)

          Increase Carer’s Allowance and Carer’s Benefit to 2009 levels (minimum)34
          Increase carer study/work hrs while receiving a carer payment from 15 to 18.5 hours.

   NWCI understands a form of GIA may have been undertaken for TCA development by KPMG as part of its actuarial review of the Social
Insurance Fund-if this is so we request release of the department’s assessment, conclusions, etc.
   CSO (2017) Women and Men in Ireland
   See Pension Section for NWCI recommendations on Homecare credit
   SJI Poverty in Focus 2019
   Family Carer’s Ireland PBS-2019 Carer’s Allowance of €219 is €1.50 less than in 2009, equalised value at 7.5% to CPI is €237 in 2019.

   Increase the earnings disregard for Carer’s Allowance so that all those on average
        industrial incomes can qualify

Invest in work-life balance policies
There is a distinct failure of the Irish social security system to recognise care work - a person is
deemed to be a new entrant if they have not contributed to the social insurance system for the
previous two years. Those that may wish to combine care work with part-time waged work,
predominantly women, find that they are not eligible for social welfare payments (i.e. Jobseekers
Allowance), are not registered as unemployed and are, therefore, discriminated against in terms of
welfare income and opportunities to participate in training programmes.

Parental Leave
NWCI acknowledge the introduction of paid parental leave for a period of two weeks that is planned
to extend on a phased basis over time. Budget 2020 should further resource the progressive
introduction of this leave. NWCI recommends that the provisions of the Act give one-parent families
the same leave entitlements as two-parent families to transfer part of the leave to other designated

Paternity Leave
NWCI welcomed the introduction of two weeks paternity leave was an important step to recognising
the role of fathers and the need to achieve a greater distribution of care between women and men.
NWCI calls for a progressive increase in the period of paid paternity leave which would allow more
fathers to care for their young children and push this out of the domain of 'women's work' for good.

Carers Leave
In Ireland, there is an entitlement to full-time' carer's leave, rather than an annual allocation of days
as per the proposed EU Directive on Work-Life Balance. Balancing caring responsibilities with work is
a growing problem for many workers, in particular women aged over 40.

NWCI Recommends

           A full & retrospective Homecare Credit
           Introduce four months’ paid parental leave
           Extend paid paternity leave to 1 month
           Introduction of six paid days of carers' leave

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